Identify PCB Containing Items

Fluorescent light ballasts that were manufactured before January 1, 1978

Fluorescent light ballasts are one of the largest sources of PCB wastes from a campus.

Must assume the ballast contains PCBs unless the words “no PCBs” are printed on the ballast

While the PCB regulations allow for disposal of ballasts and some small capacitors in local landfills, EPA recommends recycling as a preferential disposal protocol. Note that using a local landfill for disposal may involve reporting requirements under CERCLA (See CERCLA – Spills).

Dispose of any PCB items appropriately

What do I need to do?

Regulates source materials containing PCBs that are greater than or equal to 50 ppm

Regulates adjacent materials (PCB Remediation Waste) containing PCBs greater than 1 ppm as a result of a spill or leaching from source material

Prohibitions and Exceptions (40 CFR 761.20)

With a few exceptions, concentrations of source material containing less than 50 ppm are exempted from TSCA regulations
PCBs may only be used in a totally enclosed manner unless authorized under 40 CFR 761.30
Note: PCB containing caulk is not totally enclosed and is thus not authorized

Abatement Verification Flow Charts

Decontamination (40 CFR 761.79)

Background

Polychlorinated biphenyls (PCBs) are a class of organic chemicals that have been used in a variety of commercial products. PCBs were domestically manufactured from 1929 until their manufacture was banned in 1979. Due to their non-flammability, chemical stability, high boiling point, and electrical insulating properties, PCBs were used in hundreds of industrial and commercial applications including electrical equipment, surface coatings, inks, adhesives, flame-retardants, and paints.

In 1979, the U.S. Environmental Protection Agency (EPA) banned the commercial production of PCBs, citing health and environmental concerns. PCBs persist in the environment because they are highly unreactive and are largely resistant to breakdown by acids, bases and heat. PCBs are not very soluble in water, but readily soluble in fats. This solubility in fat explains why PCBs can build up in animal fat and along the food chain. Health concerns related to PCB exposure include, but are not limited to, cancer, reproductive effects and neurological effects.

PCBs are regulated by the Toxic Substance Control Act (TSCA) Title 40, Part 761 (enacted in 1976). TSCA requirements include: the manufacturing, processing, distribution in commerce, use, disposal, storage, marking of PCBs and PCB Items, record keeping and reporting.

Key TSCA Regulatory Concepts

TSCA Level Classification for Source Material

Note that the different classifications will have different requirements

“Non-PCB”:

Liquid material containing PCBs <50 mg/l or if insufficient liquid material is available for analysis, a non-porous surface having a surface concentration <10 μg/100 cm2

Non-liquid material containing PCBs <50 ppm

“TSCA - PCB Contaminated Waste”

Liquid material containing PCBs at concentrations ≥50 mg/l but < 500 mg/l or where insufficient liquid material is available for analysis, a non-porous surface having a surface concentration >10 μg/100 cm2 but < 100 μg/100 cm2

Porous Surfaces

High Occupancy Area

Any area where PCB remediation waste has been disposed of on-site and where occupancy for any individual is an average of 6.7 hours or more per week. (e.g. residences, classrooms, day care centers, work stations, cafeterias, control rooms)

Low Occupancy Area

Any area where PCB remediation waste has been disposed of on-site and where occupancy for any individual is less than 6.7 hours per week. (e.g. an electrical substation, the upper floors of the exterior of a building, a location in a facility where a worker spends small amounts of time per week such as an unoccupied area outside a building, an electrical equipment vault, or in the non-office space in a warehouse where occupancy is transitory.

Hazardous Waste

PCBs are not hazardous waste under federal regulations, although many of the management requirements are similar to those for hazardous wastes. Some states, like Massachusetts, choose to include PCBs in their RCRA Hazardous Waste programs. Therefore, management and disposal of PCBs in these states are subject to requirements of both TSCA and RCRA.